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Case No. FNK-2016-327937-1
Christine H. Chung
Juan P. Morillo
Quinn Emanuel Urquhart & Sullivan, LLP
51 Madison Avenue, 22nd Floor
New York, NY 10010-1601
Dear Ms. Chung and Mr. Morillo:
This responds to your letter dated March 24, 2016 to the United States Attorney’s Office, Southern District of New York, which was forwarded to the United States Department of the Treasury, Office of Foreign Assets Control (OFAC), requesting (1) additional guidance concerning the scope of OFAC’s blocking authority and (2) access to blocked assets in which your clients, Yani Benjamin Rosenthal-Hidalgo (Mr. Yani Rosenthal) and Jaime Rolando Rosenthal-Oliva (Mr. Jaime Rosenthal), or other designated persons have an interest, for the payment of legal fees and maintenance for your clients and their family.
OFAC Licenses
As you are aware, OFAC...
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[Update: on May 17, 2021, the FNKSR were modernized to bring its text in line with that of the typical set of blocking regulations. The change was non-substantive. See comments to 598.202. The below has not been amended to reflect the May 17, 2021 amendments to the FNKSR]
1) For general background on the case to which this guidance pertains, see the first part of the comments to Case No. FNK-2015-324389-1.
2) For comments on the specific licenses referred to in the letter, see License No. FNK-2015-323524-1, License No. FNK-2015-323572-1 and License No. FNK-2015-324386-1, comments thereto, also discussed in further detail below.
3) THE "INTEREST" and "BLOCKING" DETERMINATIONS
The application (attached in original PDF file) requests that OFAC confirm three points on the scope of its...